[Comments-com-amendment-3-03jan20] Afnic position on Proposed Ammendment 3

[Pierre Bonis]

Afnic, as the .fr registry and as a CCNSO member, but also as a technical
backend registry for various new GTLDs has no particular position on the
wholesale price for the .COM

We would only wish to remind ICANN of the dominant position of .COM in the
world domain name market, and urge ICANN to refer to the best experts of
anti-trust and competition to make sure that an increase of the .COM
prices, as well as a strong decrease if it could happen ever, have no
anti-competition effects on the market. Recognizing that ICANN is not a
price regulator, and as a member of the ICANN community, we would just
like to make sure that no negative impact on ICANN reputation could affect
us collectively in consequence of this amendment. 

 

On the "binding LoI", and referring to the DNS Security part of the
amendment, Afnic is of the opinion that this part has no place in such a
document and is even dangerous for the ICANN community. 

First, referring to the ICANN text :

"Under the LOI, Verisign and ICANN agree to work in good faith with the
ICANN community and within ICANN processes to develop best practices for
ICANN's contracted parties that can be used to create potential new
contractual obligations, tools, methods and metrics to help measure and
mitigate DNS security threats."

That LoI puts Verisign, a respected member of the ICANN community, in a
position that is outside the ICANN community. The fact that the Verisign's
action is described as being implemented "within ICANN process" doesn't
change this strange way of designating Verisign as an organisation not
part of the ICANN community. Jointly with ICANN as an organisation, and
not from the ICANN community where it belongs, Verisign would then develop
best practices that could be applied to ICANN interested parties, not with
them, but for them. The worst part being that these best practices
developed, not by and within the ICANN community as it is the rule that
bind us, but from a third party, could become new contractual obligations.


 

Afnic doesn't understand the rational of such a presentation. We are of
the opinion that there is no need to point out at a particular stakeholder
to give him a special responsibility in the policy development process,
even if the topic (the security) is of paramount importance. Inside the
ICANN community, a lot of expertise ( including Verisign's one) is already
existing, and comes from all ICANN stakeholders. 

The reference to the binding LoI in the .COM resigtry Agreement seems
therefore difficult to accept for Afnic, is the Loi itself is not strongly
rephrased 

 

On Verisign's funding to support ICANN Activities, Afnic supports and
encourage any donation from Verisign to ICANN, and welcomes this
substantial help given by Verisign as a company, and not by the .com as a
TLD. Therefore, one can only applaud this gesture in favour of the core
mission of ICANN, because it comes with no specific conditions regarding
the .com agreement itself, and therefore should not be mentioned, directly
or indirectly through the reference made to the LOI.

 

Best regards,

 

Pierre BONIS

AFNIC CEO

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://mm.icann.org/pipermail/comments-com-amendment-3-03jan20/attachments/20200214/a7000f08/attachment.html>